-4 (3) (4) Required Clothing and Equipment for Application (a) (b) (c) (a) (e) (£) One-piece overalls which have long sleeves Wide-brimmed hat. Heavy-duty fabric work gloves. Any article which has been worn while applying chlorobenzilate must be cleaned before reusing. Clothing which has been drenched or has otherwise absorbed concentrated pesticide must be buried or burned. Facepiece respirator of the type approved for pesticide spray applications by the U.S. National Institute for Occupational Safety and Health. Instead of the clothing and equipment specified above, the applicator can use an enclosed tractor cab which provides a filtered air supply. Aerial application may be conducted without the specified clothing and equipment. Handling Precautions Heavy duty rubber or neoprene [a type of synthetic rubber] gloves and apron must be worn during loading, unloading, and equipment clean-up. I hope you find this information to be useful. Should you require further information concerning the United States' regulation of chlorobenzilate, please do not hesitate to contact me. Sincerely, Richard Funkhouser Director. JON 3 1983 Mr. T. David Woo, Jr. Clerk The Senate State of Hawaii State Capitol Honolulu, Hawaii 96813 Dear Mr. Woo: Thank you for your letter of April 20, 1983, transmitting a copy of Hawaii State Senate Resolution Number 84, concerning the export of pesticides not registered for use in the United States. I am enclosing an EPA position paper which describes in general terms the Agency's policy concerning the export of Unregistered pesticides. As you will note, such pesticides are subject to labeling and notification requirements, and EPA provides foreign governments with information on the health and environmental concerns underlying our major suspension or cancellation actions. I have several further comments on issues raised in the Resolution. In practice, we do not believe that American consumers of imported food are exposed to residues of unregistered pesticides to any significant degree. Monitoring of imports by the Food and Drug Administration (FDA) finds that the large majority of imported commodities are in compliance with U.S. pesticide tolerance (legal residue level) requirements. Most of the cases which violate these requirements do not result from residues of cancelled pesticides, but rather from pesticides which are registered for some uses in the United States, but for which tolerances have not been ́established for the particular food commodity being imported. FDA is often able to rectify such problems by working directly With the exporting country's agricultural and trade authorities, since it is in their immediate economic interest 20 comply with our import requirements. 2 Concerning the first resolution, we can not agree that the proposed prohibition on the export of unregistered pesticides is a reasonable position on either philosophical For practical grounds. Our regulatory decisions on the use of pesticides are based on a weighing of the relative risks and benefits a particular use offers our society, and other nations should also be free to judge that balance of benefits and risks in the light of their own needs. The reference to public health emergencies is not a sufficient acknowledgment of differing needs, since the disruption of a major food or cash crop could be a major disaster for some nations. In addition, it is us?kely that unilateral action by the United States would have a significant impact, since Every major industrial nation, and many smaller ones produce and export pesticides. (The U.S. world market share of pesticides in international trade is about 15%). Concerning the second and third resolutions, we agree that the United States has role in international efforts to share information and develop regulatory systems for the use of pesticides. EPA, FDA and the U.S. Department of Agriculture all actively participate in the United Nations sponsored Codex Alimentarius Commission, which is developing International standards for pesticide residues in food commodities. One of the Commission's sponsoring agencies. the Food and Agricultural Organization (FAO) is also developing guidelines for pesticide registration programs, and developing a proposed Code of Conduct for the trade and use of pesticides to apply to governments, manufacturers, distributors and users of pesticides in countries which presently lack the resources and infrastructure for a comprehensive regulatory program. Through the Organization for Economic Cooperation and Development (OECD), EPA also contributes to the development of faternational standards for testing toxic chemicals, including pesticides. The In addition to international programs, EPA has on occasion been contacted directly by foreign governments for advice in designing their own pesticide regulatory systems, and we have been pleased to provide this assistance. State Department's Agency for International Development also provides extensive information and training on the ase of pesticides to other nations. As you may know, the complex issues of pesticide export policy will be the subject of a hearing June before the House Agriculture Committee's Subcommittee on Department Operations, Research and Foreign Agriculture, and EPA will be providing testimony for this hearing. |